In the U.S. access to the internet is possible for anyone. For the vast majority of employers in the U.S., advertising job openings on the internet is the surest way to get a response. But for a broadcaster with an obligation to advertise job vacancies as part of a broad outreach requirement, neither of the above is true – according to the FCC.

Seems crazy, huh? But that’s still the policy. In a challenge to an earlier FCC decision finding that a broadcaster’s web-only advertising for openings was insufficient for broad outreach to the community, the broadcaster even provided statistics to the FCC showing that more than 2/3 of homes in their area were connected to the internet, arguing that internet advertising was far more effective than print advertising. But the FCC – despite the opportunity and good facts to find otherwise – doubled down on its current policy that web-only job vacancy advertising is not sufficient to widely disseminate job information to the community. The FCC focused on the roughly 1/3 of the population that did not have readily available access to the internet.

The FCC’s policy has been around for a while, but in recent years, there’s been a call to change the policy given the rise in internet use and access. Obviously, the FCC is not ready to do that. We note that even a newspaper does not reach everyone in a community (especially given declining subscription rates), so it seems a bit pointless for the FCC to hang its hat in this decision on the numbers of homes not connected to the internet. You can read more about their rationale here.

At any rate, remember this. For broadcasters with five or more full time employees (30 hours/week) that have a job vacancy, the FCC’s EEO outreach policy does not require a set number of sources for wide dissemination of job vacancies, but it most certainly does not allow for dissemination using only the internet.